Reassessment beyond four years fails where original scrutiny examined disclosures and reopening rests solely on a change of opinion.

Reassessment beyond four years requires escapement of income attributable to the assessee's failure to make a full and true disclosure of material facts. Where the original scrutiny assessment had examined the capital-gains computation, sale transactions, loss set-off, balance-sheet and cash-flow disclosures, valuation material and sale documents, reopening without new tangible material amounts only to a change of opinion. The reassessment notice was therefore invalid.

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Issues: Whether reassessment beyond four years could be initiated when the assessee had disclosed the capital-gains computation and the underlying sale transactions during the original scrutiny assessment.

Analysis: The capital gains, set-off of losses from sale of plant, machinery and furniture, balance-sheet disclosures, cash-flow particulars, valuation material and sale documents had been specifically examined in the scrutiny assessment. The reassessment reasons did not rely on any new or fresh tangible material discovered after completion of that assessment. Reopening beyond four years required escapement attributable to the assessee's failure to make a full and true disclosure of material facts, which was absent.

Conclusion: The reassessment notice was invalid as it was founded solely on a change of opinion; the issue was decided in favour of the assessee.

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